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do not have any documentary substantiation for the expenses they
claimed on their 1992 or 1993 Schedule C.
OPINION
Schedule C Expense Deductions
Deductions are strictly a matter of legislative grace.
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New
Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
Therefore, the taxpayer bears the burden of proving that he is
entitled to the deductions claimed and of substantiating the
amounts and purposes of those deductions.3 Hradesky v.
Commissioner, 65 T.C. 87, 89-90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976). Section 162(a) provides that there shall be
allowed as a deduction all the ordinary and necessary expenses
paid or incurred during the taxable year in carrying on any trade
or business. Taxpayers must keep sufficient records to establish
the claimed deductions. See sec. 6001; Meneguzzo v.
Commissioner, 43 T.C. 824, 831 (1965); sec. 1.6001-1(a), Income
Tax Regs.
To be entitled to a deduction under section 162(a), a
taxpayer is required to substantiate the deduction through the
maintenance of books and records. Generally, in the event that a
taxpayer establishes that he or she has incurred a deductible
3 Petitioners have neither claimed nor shown entitlement to
any shift in the burden of proof pursuant to sec. 7491(a).
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